Sasser Family Companies Privacy Policy

Effective Date: November 1, 2022

Sasser Family Companies Commitment to Privacy

Your privacy is important to us. This Privacy Policy (“Policy”) explains how Sasser Family Companies (“Sasser Family Companies,” “we,” “us,” and “our”) protects your privacy when you visit this Sasser Family Companies website, app and the other sites that display this Policy (our “Site(s)”) and use of our equipment and services (together, the “Services”). This Policy describes what types of personal information we gather and track when you use our Sites, how this information is used and with whom it is shared, and your options and rights. If you have any questions about this Policy, please contact us as described below.

By visiting the Site, or using any of our Services, your personal information will be handled as described in this Policy. Your use of our Site or Services, and any dispute over privacy, is subject to this Policy and our agreement with our business customer including its applicable limitations on damages and the resolution of disputes.

The Personal Information We Collect About You

We collect personal information about you directly from you and from other entities, and automatically through your use of our Site or Services.

Personal Information We Collect Directly From You. The personal information we collect from you depends on how you use our Services. When you create a customer account, you will be asked to provide certain personal information, including your name, email address, partner/carrier/vendor status, and phone number.  When you sign up to become a carrier, we may also collect your company name and MC number. We also collect personal information directly from you if you inquire about our Services through our Site or otherwise communicate with us.

Personal Information We Collect Automatically. We automatically collect personal information about your use of our Site through cookies, web beacons, and other technologies, including:  domain name; your browser type and operating system; web pages you view on the Site; links you click on the Site; your IP address; the length of time you visit our Site and use our Services; referring URL; or the webpage that led to our Site. To the extent permitted by applicable law, we combine this information with other information we collect about you, including your personal information. Please see the section “Our Use of Cookies and Other Tracking Mechanisms” below for more information.

Personal Information Related to Vehicle Rental and Leasing and Use of Services.  When you use our Services as a driver or business customer, we, our business customer and/or the OEM or vehicle manufacturer may collect personal information about you, such as name, address, email address, phone number,  information about or from your vehicle (such as license plate number, vehicle identification number (VIN), make, model, model year, selling dealer, servicing dealer, date of purchase or lease, the lease/financing term, service history, mileage, oil/battery status, fuel or charging history, electrical system function, gear status, diagnostic trouble codes, vehicle acceleration, speed, braking and steering), your location and vehicle performance data through your use of our products or Services, and through vehicle manufacturers, telemetrics providers, our partners and others who provide information to us.  We are not responsible for the privacy and security practices of third parties and encourage you to review the privacy policies of those third party companies.

We may also collect information about your connected devices (such as mobile phone, computer, or tablet) and how you interact with our Sites and Services (such as the information described above and IP address, browser type, unique device identifier, cookie data, and associated identifying and usage information).

How We Use Your Information

We use your information, including your personal information, for the following purposes:

For Service-Related Purposes:

• To provide our products, information and Services including to fulfill our obligations to our licensors and OEMs, if applicable
• To respond to your inquiries and provide effective customer service
• for security, credit or fraud prevention purposes;
• To facilitate your ability to use the customer portal and the Site and Services
• To contact you with information and notices related to the use of the Site and Services
• To offer customization and personalized help and to otherwise personalize your experiences while using the Sites and Services

For Marketing Purposes:

• To send you marketing about our products and Services and those of our affiliated entities
• To send you news and newsletters
• To contact you with special offers and other information we believe will be of interest to you and to send you marketing about products and services of other entities that we think may be of interest to you
• To invite you to participate in surveys and provide feedback to us
• To better understand your needs and interests
• To improve the content, functionality and usability of our Sites
• To improve our products and services
• To assist us in advertising on third party websites, mobile apps, and other online services, and to evaluate the success of our advertising campaigns through third party channels (including our online targeted advertising and offline promotional campaigns).

For Research, Product Improvement, Enhanced User Experiences:

• To better understand how users access and use our Services, both on an aggregated and individualized basis. For example, we will evaluate which features of our Site are the most or least popular, and we will use this information to inform changes in our products and Services
• For research, advertising and analytics purposes
• To administer surveys and questionnaires, such as for market research or user satisfaction purposes

Legal Obligations/Protecting Our Rights and Interests:

• To comply with legal obligations, as part of our general business operations, and for other business administration purposes
• Where necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of our Terms of Service or this Policy
• For any other purpose identified in the applicable notice or other agreement with you

How We Share Your Information

We may share your information, including personal information, as follows:

Service Providers. We may use service providers to help operate this Site and deliver our Services and may share your information with service providers that provide services for or through this Site on our behalf. We currently use service providers to assist with IT hosting and similar services, contact management information, and other operational functions.

Within Sasser Family Companies and Affiliates. We may share your personal information within Sasser Family Companies (that is, among the business units within Sasser Family Companies) for the purposes as set forth in this Policy and as we otherwise notify you of or that you consent to.

Telemetrics Providers, Vehicle Manufacturers, Business Customers, Employers and Other Third Parties. Through the Services, we may also offer applications or services developed by third parties (“Third Party Application”). When you or your employer deploys a Third Party Application to your device or vehicle, the Third Party Application may collect and share information about you in connection with your  use. We are not responsible for the collection or use of information by Third Party Applications or your employer. We recommend that you carefully review the privacy statement of each Third Party Application and your employer prior to downloading or using the products and Services. We may share personal information with emergency service providers, others when required or permitted by law, and those you ask us to share information with.

Location. We may share the general and specific location of your device and/or vehicle when necessary to provide the Services to you; to comply with legal obligations; to protect the safety and rights of you and others; for product safety and security purposes; and for the purposes described in the Policy.

Tracking Technologies. We and our telemetrics providers, vehicle manufacturers, business customers, employers and other third parties may use device tracking technologies that allow us to identify you on your device and vehicle in a unique manner, such as use of IP address, to gather information about your activity within the Services, such as demographic data, browser type, pages visited, activities conducted on the page, and the day and time of your visit. We use this personal information, sometimes across devices, to measure your activity, remember your preferences, maximize and improve the performance of our Site and Services, and customize your experience. For more information about the use of tracking technologies by third parties, please see their privacy policies.

Advertising Partners. Through our Site, we may allow third party advertising partners to set technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party websites within their networks. For more information about your choices, see the “Interest Based Advertising” section below.

User Generated Content. Your user name and any information that you post to our Site and  provide through the Services, including, without limitation, reviews, comments, and text will be available to, and searchable by, all users of the Site and Services.

Business Customers/Employers. Our business customers and/or employers determine or configure how personal information will be shared within the Services.

We also disclose information in the following circumstances:

Business Transfers. If we or our affiliates are or may be acquired by, merged with, or invested in by another company or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company.  As part of the business transfer process, we may share certain of your personal information with lenders, auditors, and third party advisors, including attorneys and consultants.

In Response to Legal Process. We disclose your information to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.

To Protect Us and Others. We disclose your information when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or property, violations of this Policy, or as evidence in litigation.

As Described in a Click-Through Agreement. We reserve the right to disclose your personal information as described in any click-through agreement to which you have agreed.

Aggregate and De-Identified Information. We may share aggregated or de-identified information that does not identify users with other entities for any purpose.

Our Use of Cookies and Other Tracking Mechanisms

We and our service providers use cookies and other tracking mechanisms to track information about your use of our Site or Services. We may combine this information with other personal information we collect from you, and our service providers may do so on our behalf.

Cookies. Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and Service. There are two types of cookies: session and persistent cookies.

• Session Cookies. Session cookies exist only during an online session. They disappear from your device when you close your browser or turn off your device. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site and Services. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site and Services.
• Persistent Cookies. Persistent cookies remain on your device after you have closed your browser or turned off your device. We use persistent cookies to track aggregate and statistical information about user activity.

Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site and Services who disable cookies will be able to browse certain areas of the Site, but some features may not function.

Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web and app pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Site and Services to, among other things, track the activities of Site visitors and app users, help us manage content, and compile statistics about Site usage. We and our service providers also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.

Analytics. We use automated devices and applications, such as Google Analytics, to evaluate usage of our Site, and to the extent permitted, our Apps. We also may use other analytic means to evaluate our Site and Apps. We use these tools to help us improve our Site’s and Apps’ performance and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services. To learn more about Google’s privacy practices, please review the Google privacy policy at https://www.google.com/policies/privacy/. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt-out of targeted advertising by following the instructions in the ”Interest Based Advertising” section.

Interest Based Advertising. We and our service providers may serve advertisements on other entity websites or other media (e.g., social networking platforms). This enables us and these parties to target advertisements to you for products and services in which you might be interested. Ad network providers, advertisers, sponsors and/or  analytics or measurement companies may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These cookies and other technologies are governed by each entity’s specific privacy policy, not this one.

As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your browser preferences. To be clear, these cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. You may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page at https://optout.aboutads.info/ to opt out of interest-based advertising. Opting out from one or more companies listed on the DAA Consumer Choice Page will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads).  Also, if your browsers are configured to reject cookies when you opt out on the DAA, your opt out may not be effective. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may limit ad tracking of certain mobile ads via their device settings.

Links

Our Site and Services may contain links non-affiliated websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those websites. We are not responsible for the information practices of such un-affiliated websites.

Security of My Personal Information

We have implemented reasonable precautions to protect the personal information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security.

You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a unique and robust password for each account that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity. If you have reason to believe that your password has been compromised or used without authorization, you must promptly change it using the functionality provided on the Site.

What Choices Do I Have Regarding Use of My Personal Information?

We may send periodic promotional emails to you. You may opt-out of promotional emails by following the opt-out instructions contained in the email. If you opt-out of receiving promotional emails, we may still send you emails about your account or any services you have requested or received from us. If you have created an account or a personal profile on one of our Sites, you may be able to access and update some or all of your personal information on your account settings or profile page. In most cases, however, you will need our help. If you wish to access, update or correct your personal information, please contact us as described below. We will respond to you within a reasonable time and within the time limits established by applicable law. We may ask you for additional information to verify your identity. In most cases, we will provide access, correct or delete any inaccurate information you discover. In some cases, however, we may limit or deny your request if the law permits or requires us to do so or if we are unable to verify your identity.

Children

Our Services are not designed for children, and we do not knowingly collect data relating to children. If we discover that a child has provided us with personal information, we will delete such information from our systems.

Notice: California Consumer Privacy Act

This section of the Policy provides additional information solely for California residents, as required under the California Consumer Privacy Act of 2018, as amended (“CCPA”) and applies to their personal information as defined in the CCPA, whether collected online or offline. 

“Personal information” means information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. This and any other terms defined in the CCPA have the same meaning when used in this section. 

Note, however, that there are a number of exemptions from the application of the CCPA. Other sections of the Policy may still apply in addition to other privacy notices that we may issue addressing our specific relationship with you, including privacy notices that are sent to individuals.

We will provide a separate notice regarding the personal information we collect about job applicants or current or former full-time, part-time and temporary employees and staff, officers, directors or owners of Capstone, that is used solely in that context.

California Privacy Rights

If you reside in California and we are operating in our role as a business, you have the right to:

• request the deletion of your personal information that we collected;
• request that we disclose information about our collection and use of your personal information over the past 12 months including:

• the specific pieces and categories of personal information we collected,
• what personal information we collect, use, disclose, or sell about you
• the categories of sources of the personal information we collected about you,
• our business purpose for collecting the personal information,
  • for each category of personal information, the categories of third parties to whom the personal information was disclosed or sold;

• opt-out of the sale of your personal information; and
• be free from discriminatory adverse treatment for exercising these rights.

In order to protect your privacy and verify your request, we may require additional information from you. Please note that these rights are subject to certain exceptions under applicable law. 

Instructions You or your authorized agent can submit your request by contacting us as described below. Account holders who log in may also submit verified requests through their account profile. In general, we will verify your request and your identity when you log-in to your account and provide your name, address, or other information so that we may match it to information that we maintain about you. If you have questions or concerns about our privacy practices, you may contact us through the methods listed in the “Contact Us” section.

Information We Collect and Disclose

We have collected the following categories of personal information below from California residents within the last twelve (12) months.  The chart also lists the categories of personal information we disclose for a business purpose. Our collection, use and disclosure of personal information about a California resident will vary depending upon the circumstances and nature of our interactions with you and our business customers and employers. We share this personal information with the third parties described above in the “How We Share Your Personal Information” section.

We obtain the personal information listed above in a number of ways, including:

• Through the Site or Services. For example, when you visit our Site or use our Services or register for an account including through cookies and other technologies as described above;
• Offline. When you contact customer service or send information to our mailing address; and
• From Other Sources. Including from you, your employer when your employer registers you for an account, vehicle manufacturers, telemetrics providers, advertising partners, publicly available sources and public databases, our service providers, internet service providers, ad networks, social networks and operating systems and platforms as described above.

Our Use and Sharing of Your Personal Information With Third Parties

We use and share the personal information collected from you in the manner described in the sections above titled “How We Use Your Information” and “How We Share Your Information.”

Changes to this Policy and Your Duty to Inform Us of Changes

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. If we make any changes to this Policy, we will post the changes to our Site.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Notice: UK and European Economic Area (EEA)

For individuals in the UK and EEA, the additional provisions as outlined in Annex 1 will apply.

Contact Us

If you have questions about this policy, the privacy aspects of our Services or would like to make a complaint, please contact us in the following ways:

Email address: privacy@sasser.com

Call us: (800) 517-0455 (toll free)

Write to us at:

• Web Privacy Inquiries Sasser Family Companies
• Sasser Family Companies
• 425 N. Martingale Ave., 8th Floor
• Schaumburg, IL 60173

Additional Information for EEA/UK Users

When Acting as a Controller on the Website

Sasser Family Companies is made up of different legal entities, details of which can be found https://www.sasser.com/our-companies. This privacy policy is issued on behalf of Sasser Family Companies so when we mention “COMPANY”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the Sasser Family Group responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a product or service with us.

Purposes for which We Will Use Your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the lawful bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. The lawful bases are as follows:

• “Legitimate Interest” means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
• “Performance of Contract” means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• “Comply with a legal obligation” means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis we are relying on to process your personal data where more than one ground has been set out in the table below.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

If You Fail to Provide Personal Data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

Data Transfers outside the UK/EEA

We share your personal data between the Sasser Family Companies. This will involve transferring your data outside the UK/EEA.

Whenever we transfer your personal data out of the UK/EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed by the relevant authorities to provide an adequate level of protection for personal data.
• We may also use specific contracts approved by data protection regulators for use in the UK/EEA which give personal data the same protection it has in the UK/EEA. .

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK/EEA.

Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

• Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data. This enable you to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request transfer of your personal data. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Right to withdraw consent. Where we are relying on consent to process your personal data you may withdraw it at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No Fees Usually Required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What We May Need from You

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time Limit to Respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Right to complain to the relevant data protection regulator

You have the right to make a complaint at any time to the relevant data protection regulator.  In the UK this is the Information Commissioner’s Office (ICO) We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.